## Facts

- Randall Lee Fields, incarcerated in Michigan on an unrelated offense, was removed from his cell and questioned in a conference room by two armed sheriff’s deputies about a separate allegation of sexual conduct with a minor.
- The interview occurred in the evening and lasted approximately five to seven hours, ending after midnight.
- Fields was not given Miranda warnings and was not told he did not have to speak.
- Deputies told Fields more than once that he was free to end the interview and return to his cell.
- Fields was not handcuffed or otherwise physically restrained; the conference-room door was at times open and at times closed.
- Fields stated several times that he no longer wanted to talk, but he did not expressly request to be returned to his cell during questioning.
- After the interview, Fields waited for an escort back to his cell and returned later than his normal bedtime.
- His incriminating statements were admitted at trial and were central to his conviction for third-degree criminal sexual conduct.
- On federal habeas review under 28 U.S.C. § 2254, the district court and Sixth Circuit granted relief based on a Miranda violation; the Supreme Court reversed.

## Issues

1. Whether, under 28 U.S.C. § 2254(d)(1), Supreme Court precedent clearly established a categorical rule that a prisoner is in Miranda custody whenever isolated and questioned about conduct occurring outside the prison.
2. Whether Fields was “in custody” for Miranda purposes during the conference-room interrogation, considering all the circumstances.

## Decision

- The Supreme Court reversed the Sixth Circuit in a 6–3 decision authored by Justice Alito.
- The Court held that no clearly established Supreme Court law supported the Sixth Circuit’s categorical prisoner-custody rule; therefore, habeas relief was unavailable under § 2254(d)(1).
- On the merits, the Court held that Fields was not in custody for Miranda purposes because the circumstances—especially repeated advisements that he could end questioning and return to his cell, and the absence of physical restraints—did not create pressures comparable to formal arrest.
- Justice Ginsburg (joined by Justices Breyer and Sotomayor) agreed that AEDPA barred relief but would have found Miranda custody on these facts.

## Legal Principles

- Miranda custody is an objective, fact-specific inquiry asking whether a reasonable person would have felt free to terminate the interrogation and leave; incarceration is one circumstance, not a per se trigger.
- There is no automatic Miranda custody rule for inmates questioned in prison, including when questioning concerns conduct outside the prison.
- For prisoners, the analysis focuses on whether questioning imposes added restraints or coercive pressures beyond ordinary incidents of incarceration, comparable to formal arrest.
- Under AEDPA, federal habeas relief under § 2254(d)(1) is limited to state-court decisions that are contrary to, or an unreasonable application of, clearly established holdings of the U.S. Supreme Court; lower-court rules cannot supply the needed “clearly established” law.

## Conclusion

The Court held that AEDPA did not permit habeas relief based on a categorical Miranda rule for inmate questioning and, applying a totality-of-circumstances test, concluded that Fields was not in Miranda custody where he was repeatedly told he could end the interview and return to his cell and was not physically restrained.


Howes v. Fields, 565 U.S. 499 (2012)